Secondary Containment: Regulations & BMPs Mangement/2_Beth... · § 78a.57. Control, storage and...

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Secondary Containment:Regulations & BMPs

December 3-4| Dallas, TEXAS

Federal Secondary Containment

Safeguarding method in addition to the primary containment system

Specific/Sized◦ Indoor: Sump capacity should contain 10% of the volume of total containers or the

total volume of the largest container, whichever is greater◦ Outdoor: Plus sufficient freeboard to contain precipitation

General◦ Address typical failure mode and the most likely quantity◦ Passive or Active

SPCCSpill Prevention, Control, and Countermeasure (SPCC) 40 CFR 112

Monitors plans to prevent oil spills at facilities Oil, oil-like and oil/water mixtures

1320 gallons of above-ground storage capacity

Potential to reach “navigable waters”

Defines oil pollution as a “sheen” on the water

Clarifies “facility”; can be considered mobile or portable

Sets compliance date of November 10, 2011 for facilities that came into operation after August 12, 2002

http://www.epa.gov/osweroe1/docs/oil/spcc/spcc_101_prod.pdf

http://www.epa.gov/osweroe1/docs/oil/spcc/spcc_101_prod.pdf

SPCC 40CFR112.7(c)

The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs.

At a minimum, you must use one of the following prevention systems or its equivalent: (1) For onshore facilities:

(i) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (ii) Curbing; (iii) Culverting, gutters, or other drainage systems; (iv) Weirs, booms, or other barriers; (v) Spill diversion ponds; (vi) Retention ponds; or (vii) Sorbent materials.

SPCC Examples

Methods Description of Secondary Containment Examples

Dikes, berms, or retaining walls sufficiently impervious to contain oil

Raised earth embankments or concrete containment walls used in areas with potential for large discharges, such as single or multiple aboveground storage tanks and certain piping.

Curbing Permanent concrete or asphalt apron surrounded by a curb. Can be used where only small spills are expected and also used to direct spills to drains or catchment areas.

Culverting, gutters, or other drainage systems Types of permanent drainage systems designed to direct spills to remote containment or treatment areas.

Weirs Dam-like structures with a notch through which oil may flow to be collected. Used in combination with skimmers to remove oil from the surface of water.

Booms Form a continuous barrier placed as a precautionary measure to contain/collect oil. Typically used for the containment, exclusion, or deflection of oil floating on water, and is usually used to address oil spills that have reached surface waters.

Barriers Spill mats, storm drain covers, and dams used to block or prevent the flow of oil.

Spill diversion and retention ponds Designed for long-term or permanent containment of storm water capable to capture and hold oil or runoff and prevent it from entering surface water bodies.

Sorbent materials Materials include spill pads, pillows, socks, mats, clay, vermiculite, and diatomaceous earth. Used to isolate and contain smalldrips or leaks until the source of the leak is repaired.

Drip pans Used to isolate and contain small drips or leaks until the source of the leak is repaired. Drip pans are commonly used with product dispensing containers (usually drums), uncoupling of hoses during bulk transfer operations, and for pumps, valves, and fittings.

Sumps and collection systems A permanent pit or reservoir and the troughs/trenches connected to it that collect oil.

SPCC § 112.10 Provisions

If you are the owner or operator of an onshore oil drilling and workover facility, you must:(a) Meet the general requirements listed under §112.7, and also meet the specific discharge prevention and containment procedures listed under this section.(b) Position or locate mobile drilling or workover equipment so as to prevent a discharge as described in §112.1(b).(c) Provide catchment basins or diversion structures to intercept and contain discharges of fuel, crude oil, or oily drilling fluids.(d) Install a blowout prevention (BOP) assembly and well control system before drilling below any casing string or during workover operations. The BOP assembly and well control system must be capable of controlling any well-head pressure that may be encountered while that BOP assembly and well control system are on the well.

RCRA

Resource Conservation & Recovery Act (RCRA) 40 CFR 260-265 (generator standards) Restricts hazardous waste collection and storage Defines “characteristic” and “listed” hazardous wastes Ignitability Corrosivity Reactivity Toxicity

Exempts flowback fluids at federal level--state laws may apply May not exempt fracturing fluids at federal level

NPDES

National Pollutant Discharge Elimination System (NPDES) 40 CFR 122 Limits water pollution through permits Defines oil pollution as a “sheen” on the water Regulates stormwater discharges from construction sites (1 acre plus), industrial

facilities and municipalities Considers sediment to be the most common pollutant Requires E&P sites to have sediment controls Delegates permitting to states; all Marcellus/Utica Shale states have received

delegation

http://www.pamarcellus.com/

API Recommend Practice

Environmental Protection for Onshore Oil and Gas Production Operations and Leases (51R) Containment should be constructed so spilled fuels or chemicals do not reach the

ground Control the spread to the smallest possible area Drip pans under equipment and storage containers Retaining walls or dikes around tanks and other spill prone equipment Secondary catchment basins Permanent booms in the adjoining water basin Temporary booms deployed after the spill occurs Cleanup materials sufficient to handle small spills stocked on site

API Guidance Document

Practices for Mitigating Surface Impacts Associated with Hydraulic Fracturing (HF3) Spill prevention, response and cleanup procedures as part of SOP manual for storing

oil, chemicals or other fluids

Installation of containment, BMPs, barriers and response equipment

Sloping well location away from surface water

Retaining walls or dikes around tanks

Secondary catchment basins

Absorbent between sites and surface waters

Temporary containment and liners during drilling and completions

PA Act 13 of 2012

Unconventional well sites must be designed and constructed to prevent spills to the ground surface or off the well site. Containment practices must be in place during both drilling and hydraulic fracturing operations and must be sufficiently impervious and able to contain spilled materials, and be compatible with the waste material or waste stored within the containment. Containment plans must be submitted to the department and describe any equipment that is to be kept onsite to prevent a spill from leaving the well pad.

Containment systems shall be used wherever drilling mud, hydraulic oil, diesel fuel, drilling mud additives, hydraulic fracturing additives, and/or hydraulic fracturing flowback are stored. Containment areas must be sufficient to hold the volume of the largest container stored in the area plus ten percent. (§3218.2 of the Act)

§ 78a.57. Control, storage and disposal of production fluids

(c) Secondary containment is required for all new, refurbished or replaced aboveground primary containment, including their associated manifolds, that contain brine and other fluids produced during operation of the well. If one tank in a series of tanks is added, refurbished or replaced, secondary containment is required for the entire series of tanks. The secondary containment area provided by dikes or other methods of secondary containment open to the atmosphere must have containment capacity sufficient to hold the volume of the largest single aboveground tank, plus an additional 10% of volume for precipitation. Compliance with § 78a.64 (relating to secondary containment around oil and condensate tanks) or using double walled tanks capable of detecting a leak in the primary containment fulfills the requirements in this subsection.

§ 78a.64. Secondary containment around oil and condensate tanks

(a) If an owner or operator uses a tank or tanks with a combined capacity of at least 1,320 gallons to contain oil or condensate produced from a well, the owner or operator shall construct and maintain a dike or other method of secondary containment which satisfies the requirements under 40 CFR Part 112 (relating to oil pollution prevention) around the tank or tanks which will prevent the tank contents from entering waters of the Commonwealth.

(b) The secondary containment provided by the dikes or other method of secondary containment must have containment capacity sufficient to hold the volume of the largest single tank, plus a reasonable allowance for precipitation based on local weather conditions and facility operation.

§ 78a.64a. Secondary containment

(a) Well sites shall be designed and constructed using secondary containment.

(b) All regulated substances, including solid wastes and other regulated substances in equipment or vehicles, shall be managed within secondary containment. This subsection does not apply to fuel stored in equipment or vehicle fuel tanks unless the equipment or vehicle is being refueled at the well site.


(c) Secondary containment must meet all of the following:

(1) Secondary containment must be used on the well site when any equipment that will be used for any phase of drilling, casing, cementing, hydraulic fracturing or flowback operations is brought onto a well site and when regulated substances including drilling mud, drilling mud additives, hydraulic oil, diesel fuel, hydraulic fracturing additives or flowback are brought onto or generated at the well site.

(2) Secondary containment must have a coefficient of permeability no greater than 1 × 10-10 cm/sec.

(3) The physical and chemical characteristics of all liners, coatings or other materials used as part of the secondary containment, that could potentially come into direct contact with regulated substances being stored, must be compatible with the regulated substance and be resistant to physical, chemical and other failure during handling, installation and use. Liner compatibility must satisfy compatibility test methods as approved by the Department.


(d) Methods of secondary containment open to the atmosphere must have storage capacity sufficient to hold the volume of the largest single aboveground primary containment, plus an additional 10% of volume for precipitation. Using double walled tanks capable of detecting a leak in the primary containment fulfill the requirements in this subsection. Tanks that are manifolded together shall be designed in a manner to prevent the uncontrolled discharge of multiple manifolded tanks.

(e) All secondary containment shall be inspected weekly to ensure integrity. If the secondary containment is damaged or compromised, the well operator shall repair the secondary containment as soon as practicable. The well operator shall maintain records of any repairs until the well site is restored. Stormwater shall be removed as soon as possible and prior to the capacity of secondary containment being reduced by 10% or more.


(f) Regulated substances that escape from primary containment or are otherwise spilled onto secondary containment shall be removed as soon as possible. After removal of the regulated substances the operator shall inspect the secondary containment. If the secondary containment did not completely contain the material, the operator shall notify the Department and remediate the affected area in accordance with § 78a.66 (relating to reporting and remediating spills and releases).

(g) Stormwater that comes into contact with regulated substances stored within the secondary containment shall be managed as residual waste.

(h) Inspection reports and maintenance records shall be available at the well site for review by the Department.

(i) Documentation of chemical compatibility of secondary containment with material stored within the system shall be provided to the Department upon request.

PA DEP Oil & Gas Spill Policy

Recommends reporting a spill or release of more than five gallons of a regulated substance to the surface of the ground

Recommends notifying if the spill/release exceeds 42 gallons in competent secondary containment

Remove the spilled material from the secondary containment within 24 hours

When spilled onto the ground, the material is usually either residual waste or hazardous waste

Well Site Containments

Pad

Large square footage, typically centered off the wellheads

6 to 8 inch high berms

Tank

110% of the largest tank


Equipment

Placed under equipment that is leak prone


Chemical Storage

Placed under liquid and dry chemicals


Pad ContainmentBest Management Practices

Surface Liners

Work surfaces should be as clean and dry as possible to prevent slips and falls.

Tip: Use a felt layer to increase the coefficient of friction.

Tip: Limit wrinkled, loose layers of material to reduce tripping hazards.

OSHA 29 CFR 1910.22SPCC 40 CFR 112.7NPDES 40 CFR 122.26 RCRA 40 CFR 264.175

Composite Liners

Composite liners are slip resistant and 5X more puncture resistant.

Tip: Withstands rigging up and down.

Tip: Able to last through multiple operations.

Tip: Holes are readily detectable and easily repairable.

OSHA 29 CFR 1910.22SPCC 40 CFR 112.7NPDES 40 CFR 122.26 RCRA 40 CFR 264.175Patents: US9517596, US91517597, EP2589705B1,

AU2012201812-B2, CA2772439

Air to Fluid to Completions to FlowbackDurability

Clean Surface with Rotary Brush Between Phases

Pad Sub-base

Avoid mud.

Tip: Cement dirt should be capped with at least 2 inches of stone.

Tip: Stone should be 2 inches or less in diameter (2A-Modified, Crusher Run, #57).

Tip: Stone should rolled and firm (no rolling or pumping).

Tip: 2-4” of 2A-Modified or 2B covered by 1” of 1B is highly recommended.

Pad Layout

Start square to end square. This is especially important when using rig mats.

Tip: Square off of the main wellhead.

Tip: Mark side and account for bermingwidth.

Tip: Use sand bags to keep panels in place.

Tip: Starting and stopping lines reduce wasted material.

Seam Welding

Automated wedge welders should be usedfor all liners to join large panels together.

Tip: Set to correct temperature and speed depending on liner and site conditions.

Tip: Liner should be spotted during welding.


Leak Testing

Split welder seams can be tested by pressure.

Solid wedge welder seams can be tested by air lance and vacuum.

Tip: Vacuum tester can be moved 30 inches every 10 seconds


Patching

Plastic Liner:1) Dry surface2) Heat tack patch3) Grind edge4) Extrusion weld

Composite Liner:1) Dry surface2) Surround with sealant3) Heat tack patch4) Surround with sealant


http://images.newpig.com/wcsstore/NewPigUSCatalogAssetStore/Attachment/images/prdImgs_large/1332508927147-MAT6020_W1_L.jpg

Attachment to Cellar

Prevents leak in cellar from backing up under the liner.

Tip: Attach with ice guard, which can release if submerged for an extended period.

Tip: Attach with metal ring, which can slip.

Tip: Spray coat with polyuria, which is the most expensive.


Low-Wall Berming with Pipe

Corrugated pipe is lightweight and readily available, but can be easily crushed.

Tip: Tie corrugated pipe corners together to prevent kick out.

Tip: Edges of liner should at least reach the top of the berm to maintain sump capacity.


Low-Wall Berming with Foam

Foam is lightweight and available in different shapes and densities.

Tip: Open-cell collapses, but is absorbent to chemicals.

Tip: Closed-cell can be reused from site to site, but acts like a speed bump.

Tip: Prayer-seam into place to prevent shifting.


Low-Wall Berming with Drive-Over Ramps

Due to surface area, ramps are less likely to be buried into mud.

Tip: Use components that weight less than 35 pounds each to limit fatigue.


Maintaining the Berm

Control access to either ramps or foam berms.

Tip: Don’t park on the berm.

Tip: Don’t cut away the berm.

Tip: Plastic barricades seem to have the most success in limiting traffic.


Hole Prone Areas

Pipe Racks Use plastic mats OR Keep liner tight to

catwalk

Backyard Use rig mats for trackhoe path to drill

cutting bins

Outriggers Use outrigger pads when positioning

heavy equipment

Tank ContainmentBest Management Practices

Frac Tank Containment

110% of largest tank. Berm walls are typically metal, concrete or plastic barricades.

Tip: Subtract out tank displacement when calculating capacity.

Tip: Keep separate from pad containment. Berm should terminate, meaning no hats.

Tip: Higher sidewalls increase sump capacity for smaller areas.

Fuel Tank Containment

Fuel tanks should be double wall construction so that secondary containment travels with the tank.

Tip: Tertiary containment

Tip: Quaternary containment


Brine Tank Containment

Brine tanks are permanent structures and should have permanent secondary containment.

Tip: Install a ladder to prevent falls.

Tip: Load-line containment can prevent spills during transfer.


Infrared photograph of storage tank with a two foot oil layer on top of water

Equipment ContainmentBest Management Practices

Equipment Containment

Typically used under generators, light plants, and sewer treaters.

Tip: Can be reused from site to site.


Collapsible Storage

Lightweight and reusable spot containment can be used for tanks, separators and vehicles.

Tip: Float-up walls reduce impalement and tripping concerns.

Tip: Drive-through options eliminate need to drop and raise walls.

SPCC 40 CFR 112.7NPDES 40 CFR 122.26RCRA 40 CFR 264.175

Fluid Dispensing

Fluid dispensing is a high-risk area for spills.

Tip: Place quick-throw berms or basins under hose connections and valves.

OSHA 29 CFR 1910.106SPCC 40 CFR 112.7NPDES 40 CFR 122.26

Chemical Storage

Both liquid and dry chemicals should be on containment.

Tip: Maintain a driveway between pad containment and chemical storage containment to reduce high-traffic area.

Tip: Compartmentalize flammables and incompatible materials.

OSHA 29 CFR 1910.106SPCC 40 CFR 112.7NPDES 40 CFR 122.26

Thank You!

Lunch & Panel and Exhibits1. Lunch & State Environmental Quality Panel – 12:00pm-1:45pm Chuck Carr Brown, Ph.D., Secretary, Louisiana Department of Environmental Quality Austin Caperton, Cabinet Secretary, West Virginia Department of Environmental Protection L. David Glatt, P.E., Director, North Dakota Department of Environmental Quality Becky Keogh, Secretary, Arkansas Department of Energy and Environment Emily Lindley, Commissioner, Texas Commission on Environmental Quality

2. Exhibits Open – 1:45pm-2:15pm

Next Session – 2:15pm-3:00pm1. Understanding Cooled vs Uncooled Optical Gas Imaging – Dallas Ballroom D1

• Craig O’Neill, FLIR Systems, Inc.

2. Safer and Lower Cost Technology to Treat H2S with Plant-Based Scavenger – Dallas Ballroom D2

• Ali Naderi, Ph.D., Texas OilTech Labratories & Steven G. Hoffman, Environmental Oilfield Solutions, LLC

3. Audits: Options, Benefits, and Risks! – Dallas Ballroom D3• Sarah K. Walls, Cantey Hanger LLP

4. Environmental Compliance Challenges with Today’s Oil & Gas Acquisitions – Dallas Ballroom A1• Pete Stevenson, POWER Engineers

5. Spill Prevention Control and Countermeasures Programs (SPCC) – Dallas Ballroom A2• Donald P. Smith, U.S. Environmental Protection Agency

6. Ready for an Environmental Audit by your Customer or Shareholder Representative – Dallas Ballroom A3

• Ralph Tijerina, Goodnight Midstream, LLC

Reminder: Take the session survey in the conference app

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